Since the assessee purchased agricultural land only in March 2017, well beyond the two-year limit from the date of transfer, deduction under section 54B was rightly disallowed. However, it accepted that capital gains were taxable in AY 2017–18 on sale of flats received as consideration, with the market value of such flats (on receipt) treated as cost of acquisition. Reliance was also placed on prior assessment orders wherein the AO had consistently treated 20.01.2011 as the date of transfer. Reliance was also placed on prior assessment orders wherein the AO had consistently treated 20.01.2011 as the date of transfer. The assessee also placed on record the occupancy certificate dated 23.12.2014 and a computation chart of capital gains arising from the sale of flats.